The IRS has now issued Notice 2023-43 which provides interim guidance on its interpretation of the Secure Act 2.0’s changes to the Employee Plans Resolution System. Taxpayers may rely on the guidance until the IRS issues its update to Revenue Procedure 2021-30. The new guidance clarifies the following:
1. When does Secure 2.0 allow self-correction?
2. What types of failures may not be self-corrected?
3. What provisions of Rev. Proc. 2021-30 no longer apply?
4. What is a specific commitment to correct?
5. What is a reasonable period to self-correct?
6. Does self-correction result in a waiver of an otherwise applicable excise tax?
7. What recordkeeping requirements apply?
8. May IRA custodians self-correct before the new revenue procedure is issued?
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